This is a request pursuant to the California Public Records Act (Government Code Section 6250, etseq.) for copies of public records,[1] including, but not limited to letters, correspondence, tape recordings, notes, data, memoranda, reports, email, computer source and object code, technical manuals, technical specifications, or any other materials, held by the California Department of Justice or the Governor's office regarding the Multistate Anti-Terrorism Information Exchange (MATRIX). If this request is not addressed to the person(s) with custody and control of the requested records, please promptly forward the request to the proper official(s).

This request includes, but is not limited to, records regarding:

The state's role in the creation of the MATRIX system including but not limited to its membership on the Executive Committee of states supervising the system and the roles of Mr. Pat Lunney, California Department of Justice, and Mr. George Vinson, California Governor's office, in this effort;

The specifications for the MATRIX, including, but not limited to documents regarding storage capacities, throughput (e.g. number of identity files processed per hour), types of computers used, and user manuals;

What personal data is accessed and/or used by the MATRIX, including, but not limited to documents regarding the types of personal data (including, but not limited to drivers' records, financial records, medical information, marriage records, divorce records, Internet usage information, phone records, travel records, voting records, biometric data, educational records, information regarding race, ethnicity, immigration records, criminal justice records and/or gun owners' records) accessed or used by the MATRIX, the contents of any personal information databases related to the MATRIX, the number of individuals whose personal data has been obtained, how that data was obtained, including, but not limited to documents regarding how such data was selected for use in the MATRIX and any agreements and/or contracts to obtain such personal data, including, but not limited to any agreements and/or contracts with Seisint Inc. (Seisint).

Estimates of the cost to the state of utilizing the MATRIX, including, but not limited to projected future costs,

Any procedures for analyzing the data, including, but not limited to the criteria used by the MATRIX to determine whether someone is a terrorist or other individual engaged in a criminal enterprise, including, but not limited to the use of information regarding race, ethnicity, religious background, internet usage, travel patterns, political views, political activities and/or consumer purchasing habits in any way, shape or form;

The results of any tests or any documents, including, but not limited to any logs or other written descriptions of how any such systems is and/or has been used, the accuracy rates of any such systems while in operation and assessments of the individuals whose data was collected and used;

Who has access to the MATRIX, including, but not limited a complete list of all recipients of data from the MATRIX; any procedures for individuals to find out what information the MATRIX has about them, any procedures for individuals to correct information that the MATRIX has about them, and any procedures for individuals to find out what the MATRIX has determined about them;

Any procedures in place to protect the privacy of the individuals whose data was accessed and/or used by the MATRIX, including, but not limited to documents regarding oversight boards, login restrictions, pop-up screens at sign-on, data security measures, encryption, reduced use of certain criteria (e.g. race and/or ethnicity) and/or data checking to ensure accuracy of the information, how any of the personal data accessed and/or used by the MATRIX will be destroyed, and documentation of any policies permitting such destruction;

Details regarding usage of the MATRIX, including, but not limited to the number of times has the MATRIX been used, the cases or circumstances in which the MATRIX has been used (including, but not limited to instances where the MATRIX was used for non-terrorism investigative purposes and/or for non-criminal investigative purposes), the information that was collected in each instance, the results in instances when the MATRIX was used, including, but not limited to whether any terrorists were caught through use of the MATRIX in each instance, how many innocent people were caught through use of the MATRIX in each instance, notes or logs created during any of these instances where the MATRIX was used, and what happened to people identified by the MATRIX as a threat, the number of times the MATRIX has malfunctioned, the cases or circumstances in which the MATRIX malfunctioned, and what happened in each instance that the MATRIX malfunctioned, any procedures that are in place for use/testing of the MATRIX, including, but not limited to who decides whether the MATRIX will be used/tested in a given case, procedures for handling requests to use the MATRIX in a given case (including, but not limited to requests from state agencies, Federal agencies and/or private entities), the number of requests to use the MATRIX that have been received so far, the entities and/or individuals who have made requests to use the MATRIX, and the number of such requests that have been rejected,

Any legal analyses regarding the MATRIX, including, but not limited to documents regarding whether the MATRIX violates international, federal, state and/or local privacy laws, including constitutional protections;

Organizational details and documents regarding the development and use of the MATRIX, including, but not limited to documents regarding sources of technical and/or financial support for the MATRIX, which federal, state and/or local government agencies are involved and/or cooperating in the MATRIX project, memoranda of understanding between federal, state and/or local government agencies and private companies or other agencies, the extent to which such agencies are involved and/or cooperating in the MATRIX project, what companies (including, but not limited to Seisint), consultants and/or colleges are involved and/or cooperating in the MATRIX project, the extent to which such companies, consultants and/or colleges are involved and/or cooperating in the MATRIX project, what companies, the amount of money spent on developing the MATRIX system so far, the sources for this money, and budgetary outlays for future development and/or maintenance of the MATRIX;

Records regarding state or federal oversight of the MATRIX or Seisint;

Records regarding training of people to use the MATRIX, including, but not limited to textbooks, video presentations, contracts and/or agreements to be signed by MATRIX trainees, and the number of people who have been trained to use the MATRIX so far; and

Any records regarding the state's decision to withdraw from the MATRIX.

This request also includes, but is not restricted to information regarding similar activities being conducted by any public and/or private agency or organization.

The California Public Records Act requires within ten (10) days either production of the requested documents and/or notice of the specific reasons why the materials requested (or portions thereof) are exempt from disclosure. Please send the records to us at the address shown above. If necessary, we will reimburse you for reasonable copying costs.

If you have any questions regarding this request, please feel free to contact us at XXX. Thank you in advance for your timely cooperation.

Very truly yours,

Christopher CalabreseCounsel, Technology & Liberty Program

Barry SteinhardtDirector, Technology & Liberty Program

[1] The term ""record(s)"" as used herein shall mean ""all documents, papers, letters, maps, books, tapes, photographs, films, recordings or other material, regardless of physical form or characteristics, made or received pursuant to law or ordinance or in connection with the transaction of official business by any agency.